From basic overview to solution selection criteria, this report is your go-to guide to ensuring compliance with the ELD mandate.
If You’re Frustrated By The ELD Mandate, Consider These 3 Points
Many of the companies I’ve spoken with that are impacted by the ELD (electronic logging device) mandate are frustrated by its existence. While that’s understandable in the sense that most people don’t enjoy being told what to do and when, you have to move past your frustration to look not only at the “why” behind the mandate but also at the opportunity it presents. If you are one of those people feeling frustrated, I urge you to consider these three points.
The Safety Benefits Of ELD Are Huge
One of the primary reasons that the U.S. Federal Motor Carrier Safety Administration (FMCSA) enacted
the ELD mandate was to address a variety of safety concerns, which we’ll discuss in more detail in this report. Think about what this means for your company and, even more importantly, your drivers. Ensuring safe operations benefits everyone: It protects your drivers, it helps your company to reduce liability and insurance costs, and it keeps the community at large on the roads safer, too. Yes, going through the exercise of obtaining an ELD solution and making changes to how your employees currently operate can seem daunting — but the increase in safety alone is worth the headache.
ELD Also Improves Efficiency
If you’re like many organizations, the value of safety can be difficult to measure. While I assure you it is significant, let’s shift our focus to a more tangible benefit that ELD will bring — an increase in efficiency. The elimination of paper forms and manual processes that the mandate brings about will have a significant impact on your operations. Yes, you have to come to grips with the investment and get over the hurdle of change, but the benefits of streamlining and automating these processes will be clear.
The Mandate Is An Opportunity
If you’re wasting time being frustrated about this, try shifting your perspective to look at the opportunity the ELD mandate brings. In all honesty, regardless of the mandate, eliminating your paper processes and embracing the digital age are changes you should be making anyway. Embracing what technology can do for your company is what leading organizations in 2017 are doing (or have been doing). The changes you’ll make as part of compliance with the mandate provide benefits far beyond that compliance itself and will truly enable you to transform and modernize your operation. These technologies can be used beyond ELD compliance to deliver valuable data that can help your company’s management make far better decisions, to deliver far better service to your customers, and even as a way to attract new talent to your organization.
I understand that change can be frustrating, especially when it’s required. But I challenge you to put those emotions aside and embrace the fact that this mandate really is a great opportunity for your business. Once you shift your perspective to look at it that way, you’ll start to see some of the ways that you can really take advantage of this change to improve your operations. The companies that look at this mandate beyond simply checking boxes to become compliant will be able to use these technologies in ways that can deliver significant business impact. If the mandate applies to you, you have to make these changes whether you decide to make the most of them or not — so I urge you to do just that.
Publisher/Editor in Chief
The ELD Mandate, Simplified
As part of the Moving Ahead for Progress in the 21st Century (MAP-21) Act, Congress required adoption of the ELD (electronic logging device) mandate. The ELD final rule was enacted at the end of 2015 by the U.S. Federal Motor Carrier Safety Administration (FMCSA) with compliance required by Dec. 18, 2017. To simplify an understanding of the ELD mandate, let’s look at three areas of information: the what, the why, and the who.
What Exactly Is The ELD Mandate?
The ELD mandate requires commercial drivers who are required to prepare hours-of-service (HOS) records of duty status (RODS) to do so using ELDs. An ELD is a technology that automatically records a driver’s driving time and other HOS data for accurate record-keeping. An ELD monitors a vehicle’s engine to capture data on whether the engine is running, when the vehicle is moving, miles driven, and duration of engine operation (engine hours). Essentially, an ELD takes all of the information a driver is currently required to keep on paper and does so automatically, electronically.
The mandate sets ELD performance and design standards and requires ELDs to be certified and registered with FMCSA. The mandate establishes what supporting documents drivers and carriers are required to keep, and it prohibits harassment of drivers based on ELD data or connected technology (such as fleet management).
Why Was The ELD Mandate Put In Place?
The primary driver of the ELD mandate is to increase safety of both drivers and the general public on the road. “The MAP-21 Act was put into effect to help the FMCSA reduce crashes, injuries, and fatalities involving large trucks and buses,” explains Ryan Driscoll, marketing director at GPS Insight. “The ELD mandate’s intent is to help the FMCSA hold businesses accountable for higher safety standards and to gain the ability to prevent high-risk drivers and vehicles from being on the road with the general public.”
The FMCSA projects significant safety benefits from the ELD mandate. “The FMCSA estimates that the ELD mandate will help avoid 1,844 crashes, 562 injuries, and save 26 lives annually,” says Todd Ewing, director of product marketing at Fleetmatics. “This data is based on the improved compliance with HOS regulations that ELDs will provide.”
One of the biggest risks of manual HOS logging is that when data isn’t accurate, there is a greater likelihood of having fatigued drivers on the road. “The ELD mandate helps to better manage drivers’ HOS and fatigue by more accurately measuring the amount of duty time drivers spend on public highways,” says Sid Nair, senior director, transport and compliance at Teletrac Navman. There are stipulations on how many hours a driver can operate a vehicle in certain time frames, and automating HOS logging helps to ensure that drivers don’t exceed those limits, putting themselves and other people on the road at greater risk. With the lower risk comes less potential for accident and insurance costs.
Beyond the primary benefit of improving safety on the road, there is plenty more that companies stand to gain from ELDs. “There are some obvious benefits when a carrier installs and implements ELD. The administrative work around reporting HOS and managing RODS will be significantly decreased, because an ELD eliminates the manual process of completing forms and lowers the possibility of errors,” says Jason Rudinoff, regulatory compliance analyst and safety specialist at ARI. “Carriers may see an increase in efficiency and productivity since their drivers will no longer need to spend time completing paper logs.”
Consider looking beyond what it will take to just become compliant, and think about how this technology could have a greater impact. “Beyond ELD compliance, these technology platforms can facilitate route optimization, proof of delivery [POD], the ability to scan product on and off vehicles to better track inventory, and integrating the access of real-time vehicle diagnostic data,” says Jim Dempsey, executive business development for mobility at Panasonic.
Let the ELD mandate compel you to discover all ofthe ways you can bring your business into the digital age. “Companies that are new to deploying telematics and mobile devices can expect to benefit from digital transformation — the automation of traditionally paper-based processes,” says Ewing. “Paper forms such as trip sheets will be replaced with electronic forms. Manual processes such as driver status ‘check calls’ will be handled through automated updates regarding vehicle location and job status. Other automated workflow processes can be integrated with back-office or mobile applications. Companies can experience benefits such as reducing billing disputes associated with lengthy detention or delay times at shipper/receiver locations, improving driver relations stemming from better payroll visibility, and easier dispute resolution due to electronic records. Companies can also use the engine diagnostic reporting to improve uptime and reduce unscheduled repairs on their vehicles.”
These capabilities translate to real ROI. Based on assumptions stated by the FMCSA in its Regulatory Impact Analysis for ELDs, paperwork savings per driver per year are estimated to include:
- Driver filing RODS: $487
- Driver submitting RODS: $56
- Clerk filing RODS: $120
- Elimination of paper driver log books: $42
Combined, that is $705 per year in paperwork savings alone. If you’re wondering how the FMCSA came up with those numbers, the agency estimates that each truck driver fills out an average of 240 RODS per year, and an ELD is estimated to reduce the amount of time drivers spend logging their HOS by 4.5 minutes per RODS — or, 19 hours each year. They also note the time commercial drivers spend filing or forwarding their RODS to carriers, which the agency estimates takes five minutes and occurs 25 times per year — eliminating two more hours a year. In short, that’s a potential 20-plus hours of drive time wasted by filing and sending paper driver logs.
Whom Does The ELD Mandate Impact?
Generally speaking, the rule applies to most carriers and drivers who are required to maintain RODS data, which is the majority of commercial motor vehicles. The rule applies to commercial buses as well as trucks, and to Canada- and Mexico-domiciled drivers. “The current HOS requirements set by the FMCSA to help identify vehicles subject to the new regulations include vehicles that weigh 10,001 pounds or more; buses used to transport nine or more passengers, including the driver, for compensation; buses used to transport 16 or more passengers, including the driver, not for compensation; and vehicles transporting hazardous materials requiring placards,” notes Driscoll. “The industries this typically covers include aggregate haulers, construction, energy, food distribution, freight/goods transportation, and passenger transportation.” According to the FMCSA, the ELD mandate has some limited exceptions, including:
- Drivers who operate under the shorthaul exceptions may continue using timecards; they are not required to keep RODS and will not be required to use ELDs
- Drivers who use paper RODS for not more than eight days out of every 30-day period
- Drivers who conduct drive-away-towaway operations, in which the vehicle being driven is the commodity being delivered
- Drivers of vehicles manufactured before 2000.
“Some fleets will benefit from the grandfather extension where fleets will not have to begin using an ELD on Dec. 18, 2017 if they have installed a grandfathered AOBRD [automatic on-board recording device] prior to the implementation date,” explains Driscoll. “In addition, the FMCSA will allow these AOBRDs to be moved to new commercial vehicles, replacing the ones in which they were originally installed prior to Dec. 18, 2017. The FMCSA is clear that new AOBRDs cannot be purchased and installed after Dec. 18. Although these exceptions exist now, it is important to keep in mind they won’t exempt your fleet indefinitely.”
As referenced, the timeline the FMCSA has set for compliance states that all carriers and drivers subject to the ELD rule must use either an ELD or an AOBRD compliant with existing regulations by Dec. 18, 2017. AOBRDs may be used until Dec. 16, 2019 if the devices were put into use before Dec. 18, 2017. Starting Dec. 16, 2019, all carriers and drivers subject to the rule must use ELDs, and ELDs must have the capability of either telematics data transfer or local transfer.
Failure to comply with the ELD rule can lead to fines, penalties, and even operations being shut down.
Selecting The Right ELD Solution For Your Company
If the ELD mandate applies to you and you don’t already have a solution that enables you to comply, the writing is on the wall that you need to find one — and fast. That said, as with many technologies today, there is a multitude of solutions on the market touting better features and functionalities. To help you create your company’s ELD solution criteria and jump-start your selection process, we’ll take a look at which capabilities you’ll need.
Before we do that, though, let’s talk about what you can expect your ELD solution to cost. The FMCSA commissioned a study to gauge the economic impact the mandate will have on fleets and, in doing so, found that on average, ELD costs approximately $495 per year or about $41.25 per month, per vehicle. This estimated cost takes into account the acquisition of the hardware and software, installation of the solution, and training for your drivers. Depending on the vendor you choose to obtain your technology, you may have options either to pay up front, finance over time, or even rent the devices.
The FMCSA believes the total annual cost of ELD adoption will be $975 million, which includes all equipment for carriers and commercial truck inspectors, as well as inspector and driver training. That said, the net benefits of ELDs outweigh the costs, with expected paperwork savings of over $1.6 billion annually, plus crash reduction costs of $395 million. While the ELD mandate does require you to make an investment, the FMCSA has done its homework to ensure that the ROI is there. And, if you look at this as an opportunity to use the technology strategically — versus simply for compliance — you will reap more benefits.
Key ELD Features & Functionalities
To help your decision-making process, the FMCSA has developed a checklist of the key features and functionalities required by every ELD:
- Provides separate driver and manager accounts
- Synchronizes with the engine control module
- Automatically records driving time
- Retains data for the current 24-hour period
- Retains data for the previous seven days
- Prevents device tampering
- Requires driver to review unidentified driver records
- Allows driver to obtain ELD records on demand
- Supports electronic data transfer
- Displays required data for authorized safety officials
- Requires driver annotations for edited records
- Provides ELD user manual
While this checklist serves as a good reference to ensure that your selected solution meets the FMCSA criteria, there are still many factors that will come into play as you evaluate ELD vendors. Many of those factors will be dependent upon your company’s operations and goals for the solution, but there are a few categories that are universally applicable.
The first of those is ease of use. You want to find a solution that has an interface that is easy for the drivers to understand and use and that presents data in a way that is simple for management to use. It’s likely that every solution on the market will tout “easy to use,” so your best bet in finding one that you feel truly is easy to use is to test a few (at least). All too often, companies base technology decisions on cost alone and select the least expensive without really even doing their research. Let me caution you against doing so. That certainly doesn’t mean you’ll find that the most expensive solution is easiest to use — but it does mean you need to do your research. Ease of use is an important criterion, because it is tied directly to the likelihood of your drivers adopting the system. Pushback is normal and likely unavoidable to an extent, but choosing a solution with a clean user interface will help you speed adoption of the solution as you overcome those concerns — while a poorly designed solution will only compound your problems. “Your drivers are less likely to report their time correctly if it is difficult to update their status or provide compliance updates,” adds Rudinoff. “Similarly, if the user interface is difficult to use, the anticipated ease in the administrative burden may never materialize. Even worse, if it is hard to access and manage the data, you may run into compliance or reporting issues.”
For many companies subject to the ELD mandate, durability is also a chief criterion. Oftentimes transportation environments can be rough — bumpy rides, dust, extreme temperatures — and if that’s the case for your operation, you need to select a device that can withstand those operating conditions.
As you think through your ELD deployment, don’t forget to consider a few peripheral points, for instance, the dock-ing/mounting of your ELD within the vehicle. “Having a safe, reliable mounting solution is critical,” says Dempsey. “The mounting solution needs to be able to withstand the same vibration and thermal standards that the devices do, while also preventing those devices from becoming projectiles in the event of an accident.”
If you are using a smartphone or tablet-based ELD, you also need to consider connectivity. “Many long haul truck and fleet drivers travel extensive distances through areas where cellular signal is weak,” says Frankie Smith, VP of sales at SureCall. “In these instances, a cell signal booster can ensure data is able to be transferred to dispatch at all times.”
The BYOD Vs. In-Vehicle ELD Debate
Another major ELD decision is whether you want to take a BYOD or an in-vehicle device approach. A BYOD approach means that your drivers carry smartphones or tablets that communicate with their trucks via additional technology. They are personal devices that the employees bring with them to use for work, as well as personal purposes. With an in-vehicle solution, the devices are permanently mounted in the vehicles. While there are pros and cons to both options, it seems the vendors I interviewed mostly agree that an in-vehicle approach will make more sense for the majority of fleets impacted by the ELD mandate.
Let’s first discuss the BYOD option. The pros of BYOD include lower up-front costs, because employees are using their own devices. Training and change management may be easier to tackle in a BYOD environment because the drivers are used to, and comfortable with, their devices. “For a small fleet looking for a solution that is simple to use and easy to install, as well as economical, BYOD might be a good fit,” says Rudinoff.
As Ewing points out, there can also be more flexibility in a BYOD environment. “Many built-in solutions are more expensive and less configurable, with fewer app choices,” he says. “This often limits a company’s ability to be innovative and flexible.” However, if you’re getting excited about how inexpensive and easy BYOD sounds, there are some important points to consider. One is that it is far easier in a BYOD environment for the drivers to risk non-compliance — whether through forgetting their devices, forgetting to plug them in, the batteries dying, and so on. Putting the control more in their hands means that there is more opportunity for the solution to be improperly utilized or not utilized at all.
A second concern with BYOD is distraction. Drivers are not legally allowed to hold or interact with devices while driving, and if the devices they are carrying are their personal smartphones, drivers can be more tempted to do so.
Finally, there are issues with BYOD related to security and intended device use. How do you secure their personal devices? How do you ensure that they aren’t using the devices for personal purposes during working hours? What company data will be on the devices if they are lost or stolen? These are important points to think through and develop a plan for if you are considering BYOD. Further, some would say that the savings of device acquisition is offset over the long run. “Savings that are realized up front with BYOD often end up costing more in the long run,” says Dempsey. “Several studies have shown that while the procurement costs are removed from the equation, there is a larger expense in IT support that goes into managing BYOD devices.”
An in-vehicle approach alleviates many of these concerns. It’s a dedicated mobile console within the vehicles for drivers to do all of their work on. You don’t have to worry about forgotten devices or dying batteries. It’s far harder for drivers to risk non-compliance.
As you’re evaluating potential ELDs, you will want to consult with FMCSA’s ELD registry, which provides a list of self-certified devices that meet all currently published requirements (more on this later).
BeWare These Three Common ELD Misconceptions
I’ve learned through conversations with our readers that there are some misconceptions about what the mandate means, the technology that will enable compliance, and how the change will impact operations. The vendors I interviewed corroborated and pointed out some additional misconceptions as well.
It’s OK To Wait
The first misconception is that this isn’t an urgent issue. December seems pretty far away, right? Wrong! The clock is ticking, and four months isn’t long at all. Perhaps your ELD deployment is well underway; but if not, you should start working on it immediately. Holding off too long will force you to rush, and rushing will cause you a number of avoidable headaches — including selecting a less-than-optimal solution because you speed through evaluation, not to mention the pushback you’ll get from the drivers, because you forced such a major change on them so quickly. Your ELD research and evaluation should be well underway to allow your company ample time for a successful deployment, including training and change management.
“There are four major reasons why procrastinating until Q4 is a bad idea. ELD inventory will be a supply chain nightmare, there will be a shortage of professional installers, ramping up and training your team doesn’t happen overnight, and you may be forced to settle for just any system to be compliant [even if it isn’t the best fit for your company’s needs],” says Driscoll.
All ELDs Are Created Equal
Another common misconception is that all ELDs are created equal. Not only is this not true, but even if it were, not all are created to be equally beneficial for your company’s specific needs. The only way to determine a best fit is to evaluate and even test multiple solutions.
As mentioned earlier, the FMCSA is trying to alleviate this issue by offering its registry of certified ELDs. While this registry provides criteria you can make sure your ELD provider has checked, you do need to keep in mind that certification is self-certification — there aren’t yet any standardized ways to test compliance. Consequently, just because a vendor is self-certified doesn’t mean that its solution has been validated to meet any certain criteria.
“Dozens of new providers have jumped into the market and ‘self-certified’ their solutions,” cautions Ewing. You need to make sure you do your due diligence on any vendor you evaluate to ensure the solution is indeed compliant, to evaluate the vendor’s stability and expertise, and to select a solution that is right for your company’s needs.
Deployment Will Be Easy
If your drivers are already leveraging technology for their jobs, then perhaps ensuring compliance with the ELD mandate will be a simple change for you. However, if your organization is one currently using paper logs and you have drivers who are used to a manual way of conducting business, it’s most likely a misconception to think this change will be easy. Selecting the right ELD is step one, but don’t overlook the need to really think through how to manage this change to ensure adoption.
“There’s a huge misconception to overcome in that many drivers think this technology is nothing more than ‘Big Brother’ and only being used to track their movements, habits, and activity,” says Dempsey. “You need to be able to communicate to employees the reasons for the ELD rule and how your company will and won’t be using the data. Having champions from your driver community is critical.” The best first step to successfully manage the change is to formulate your plan for doing so. “It is important to communicate often with the individuals who will be affected and in as much detail as possible,” says Rudinoff. “Plan ahead, so you can be clear on how the program will work, what the implications will be, what everyone’s individual responsibilities will be, what training will be available, and how questions will be answered. And be open to feedback.”
Beyond open, two-way communication, training will be imperative not only to foster adoption but also to ensure that compliance occurs. “Keep in mind how much training employees will require — both drivers and office staff — and create a continuous training schedule in collaboration with your ELD provider,” says Nair. “You need to educate compliance managers, drivers, administrative personnel, and other ELD users on compliance requirements and processes, supporting document requirements and processes, ELD operation, proper editing of records, ELD data retention, understanding and preventing harassment and coercion, and ELD troubleshooting.” When creating your change management strategy, focus on the positive. “Electronic logging offers a welcome relief from a task that has historically been labor intensive,” says Ewing. “ELDs minimize interruptions from the back office, maximize driver time, eliminate paper log books, improve safety, offer the opportunity to be recognized or rewarded for compliance and good driving, and streamline roadside checks.” Your communication plan should be heavy on playing up these benefits for employees so that they can get excited about what this change will do for them.
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Field Technologies Magazine, A Special Report – Your Essential Guide to the ELD Mandate – FieldTechnologiesOnline.com